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STRANAHAN v. COMMISSIONER OF INTERNAL REVENUE

No. 5502.

42 F.2d 729 (1930)

STRANAHAN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

June 27, 1930.

Attorney(s) appearing for the Case

T. O. Marlar, of Toledo, Ohio (E. J. Marshall and Marshall, Melhorn, Marlar & Martin, all of Toledo, Ohio, on the brief), for petitioner.

J. H. McEvers, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, and J. S. Franklin, all of Washington, D. C., on the brief), for respondent.

Before DENISON, MOORMAN, and HICKS, Circuit Judges.

MOORMAN, Circuit Judge.

This is a petition to review an order of redetermination entered by the Board of Tax Appeals assessing a deficiency in income taxes against the petitioner for the year 1921 in the amount of $61,744.19. The assessment was based upon disallowances of losses claimed to have been sustained on loans to Clarence E. Earle and to the Jeffery-DeWitt Company.

The Earle loan arose in this way: In 1920 Earle was carrying an account with a brokerage...

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